Subject: Rule 15c2-11; a better way - the intermediate private-sector
Date: 01/19/2000 7:41 PM
Obviously, the primarily responsible investing community has no use for the
Rule 15c2-11 proposals.
I find a lot of their arguments have merit, and the "chop shops" and
swindlers will have no respect for the regulation to begin with.
Would it not seem more practical to include an intermediadate tier of SEC
approved and independent CPAs, who are payed by the SEC (which would derive
the funding by application fees). The Class-SEC (at-arms-length) CPAs would
review all applicants for public trading (Pink, BB, or otherwise) and both
certify and follow the activities of the applicants - removing this burden
from the Market Makers.
No Class-SEC (at-arms-length) CPAs approval, no MM, not quotes, no
trading......
If there are violations of this system, the Class-SEC (at-arms-length) CPAs
and the slimeoid CEO both get sentenced to the Government funded Milken
golf-club. And, it's a one-time, one-screw-up deal. You don't ever come
back to trade or work in the system if you foul-up.
"0"-tollerence, no "..Uncle Alan [Greenspan].." want's him to have another
chance...!!
In electrical construction, you only hire a bonehead/thief once..!! In the
military you only violate your secrecy agreement once. Is there some reason
that philosophy won't work in the Securities Business..??
A response would be appreciated.
Respectfully,
John M. Hollen, EE